[Awclist] [Fwd: RRFW Riverwire -NPS PROPOSES REMOVING THE WILD FROM WILDERNESS ]

[Thomas Robey]

-------- Original Message --------
Subject: 	RRFW Riverwire -NPS PROPOSES REMOVING THE WILD FROM WILDERNESS
Date: 	Sat, 21 Jan 2006 22:51:10 -0700
From: 	Riverwire <riverwire at rrfw.org>
Reply-To: 	<Riverwire at rrfw.org>
Organization: 	River Runners for Wilderness
To: 	riverwire at rrfw.org



RRFW Riverwire –NPS PROPOSES REMOVING THE WILD FROM WILDERNESS

January 21, 2006

Heads UP river runners! Your comments are needed! The National Park 
Service has revised all of its national policies, including its 
wilderness review and stewardship policies, and is soliciting public 
comments on new Draft policies until February 18, 2006.

Instead of wild, undeveloped places associated with solitude and 
self-reliance, under the new policies wilderness would be managed for 
intensive commercial recreation, scientific uses and special events. The 
National Park Service would actively promote and facilitate commercial 
services in wilderness. Facilities and new developments would be 
justified on the basis of improving visitor safety and enhancing visitor 
use. The fallout will be particularly onerous on the river in Grand 
Canyon if these policies are adopted.

The NPS oversees more wilderness acreage than any other agency, so 
PLEASE let the Park Service hear your thoughts and concerns!!

SUMMARY OF MAJOR PROBLEMS WITH THE NEW DRAFT POLICY:

- Defines public use as the primary purpose of wilderness. Downplays 
preservation of wilderness character as the singular statutory purpose 
of the Wilderness Act.

- The draft policies place major emphasis on encouraging and 
facilitating commercial uses in wilderness.

- Emphasizes visitor safety as a major goal of wilderness management, 
and allows all sorts of developments in wilderness to enhance safety -- 
administrative cabins, signs, trail developments, outfitter caches, 
toilets , developed camp sites -- even picnic tables!

- Modifies the current wilderness review process, making it easier for 
political appointees in the Executive Branch to shield areas from 
further consideration as wilderness by not forwarding complete 
information to the President for ALL areas that have undergone a 
wilderness suitability study.

COMMENT POINTS TO CONSIDER:

Purpose of Wilderness and the Wilderness Act

1. CRITICAL! The revised policies misconstrue the six "public purposes" 
(uses) listed in section 4(b) of the Wilderness Act as the primary 
"purposes" of the Act (i.e. recreational, scenic, scientific, 
educational, conservation, and historical uses).

Tell NPS that the statutory purpose of the Wilderness Act is singular, 
not plural -- the Wilderness Act is clear that the purpose of the Act is 
to preserve the wilderness character of each area in the National 
Wilderness Preservation System, not to promote any particular use!

2. CRITICAL! A primary emphasis in the policies is on "accomplishing" 
the six "public purposes" (uses) by accommodating, encouraging, and 
facilitating public use of wilderness.

Tell the NPS that NPS policies should emphasize appropriate types and 
amounts of public wilderness use to the extent that they are compatible 
with protection of an area's wilderness character, including the area's 
undeveloped, non-motorized qualities and wilderness solitude.

Wilderness Suitability Review:

/Helpful Background: / NPS does an initial screening of all NPS lands to 
identify those areas that have wilderness characteristics and are 
therefore suitable and eligible for further consideration as wilderness. 
NPS then conducts a more formal "wilderness study" of all lands 
identified by the initial screening as suitable and eligible for 
wilderness designation.

1. CRITICAL! The revised policies would allow a political appointee -- 
the Secretary of Interior -- to administratively shield suitable areas 
from further consideration as wilderness by not forwarding complete 
information to the President for ALL areas that have undergone a 
wilderness study. This means that if the Secretary does not recommend an 
area for wilderness designation then (s)he could simply decide not to 
forward any information about that area to the President for his review. 
However, the Wilderness Act/ explicitly/ requires the Secretary of 
Interior to forward recommendations to the President regarding both the 
suitability AND non-suitability for/ all/ areas that have undergone the 
formal wilderness study process. By not forwarding recommendations for 
those areas deemed by the Secretary to be unsuitable for wilderness, the 
Secretary inappropriately hinders the President's opportunity and 
statutory right to fully review and modify all wilderness 
recommendations made by the Secretary.

Please tell NPS this policy change is illegal under the Wilderness Act 
and that the Secretary MUST forward both suitable AND non-suitable 
recommendations on to the President for all areas that have undergone a 
formal wilderness review!

Visitor Safety, Use, and Developments

1. CRITICAL! The new policies focus intensively and inappropriately on 
assuring visitor safety as a central goal of wilderness management. The 
policies specify that improving safety is an appropriate reason to allow 
the development of recreational and administrative facilities in 
wilderness, including new trail developments, administrative cabins, 
trail shelters, signs, developed campsites, and toilets -- even picnic 
tables!

Tell NPS that the Wilderness Act intended wilderness to remain/ in 
contrast/ to our developed and highly regulated modern world. Tell NPS 
that wilderness should remain a place of challenge, discovery, risk, and 
self-reliance, not managed and developed to promote visitor safety! 
Developing facilities to enhance safety is inappropriate action in 
wilderness.

2. CRITICAL! The new policies place major emphasis on NPS encouraging 
and/ facilitating/ visitor use of wilderness, including promoting the 
use of commercial outfitting services.

Tell NPS that it's not their job to promote increased use in wilderness 
or market wilderness as a recreational playground. By law, their job is 
to preserve wilderness character and develop public awareness and 
appreciation for the qualities and values that make wilderness unique 
and different from non-wilderness national park backcountry that may be 
managed primarily as a recreational resource.

Administration

1. Administrative Facilities -- the new policy would allow permanent 
administrative equipment caches and construction and maintenance of 
Ranger cabins in wilderness if these are "necessary to protect an area's 
wilderness character." NPS frequently uses helicopters to access such 
facilities where they currently exist in wilderness.

Tell NPS that permanent caches and cabins are NEVER necessary to protect 
wilderness and in fact degrade and compromise wilderness character by 
intruding on the undeveloped, remote, qualities that make wilderness 
unique. Tell NPS that Rangers can access and camp in wilderness via the 
same non-motorized, traditional, self-reliant means that other 
wilderness visitors do. NPS should be leading the way in setting a good 
example for other visitors in regard to appropriate wilderness ethics 
and travel techniques.

2. Minimum Requirement / Minimum Tool Analysis -- NPS policies currently 
allow each park superintendent to devise their own method for conducting 
a "Minimum Requirement" Analysis to assess the need and appropriateness 
for various administrative activities in wilderness.

Tell NPS that most superintendents have no experience in designing a 
Minimum Requirement Analysis. A standardized Minimum Requirement 
worksheet should therefore be required and be subject to public comment 
and review in order to improve consistency, accountability, and public 
understanding across all park wildernesses.

3. Monitoring -- The new policies define the purpose of wilderness 
monitoring, in part, as "ensuring that the public purposes (uses) of 
wilderness are being met."

Tell NPS that wilderness monitoring is about preserving wilderness/ 
values / and wilderness/ character/, not about assuring that sufficient 
public use is occurring. Wilderness monitoring must focus on more than 
biophysical carrying capacity -- its central focus must be on assuring 
that the unique qualities and values of wilderness character are 
respected and preserved.

Your letter to the NPS is very important!

The draft policies are online at:

http://parkplanning.nps.gov/document.cfm?projectId=13746&documentID=12825

COMMENTS DUE: February 18th, 2006 (e-mailed by midnight MST, or 
postmarked that day, please include your full name and contact information)

SEND TO: waso_policy at nps.gov


Or:

Bernard Fagan, Room 7252
National Park Service
Office of Policy
1849 C Street, NW
Washington, DC 20240

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